Case Summary (G.R. No. 220367)
Facts and Procedural History
On September 25, 2001, EEIPI filed a complaint for qualified theft against Hu, alleging misappropriation of funds amounting to Php 762,076.35. It was claimed that Hu, during his tenure, issued a check payable to himself without any legitimate business justification. After an audit of EEIPI's financial transactions, Villanueva's affidavit established that Hu wrote the check outside the bounds of his authority. Initially, the Office of the City Prosecutor dismissed the complaint due to insufficient evidence, prompting EEIPI to appeal.
DOJ Resolution and Appeal
On July 10, 2002, the Department of Justice (DOJ) reversed the earlier dismissal, citing the absence of documentation supporting Hu's claim that the check represented a commission for sales. The DOJ directed the City Prosecutor to file an information for qualified theft against Hu. Consequently, the City Prosecutor filed charges on July 18, 2002, with an initial bail recommendation of Php 40,000.
RTC's Orders on Bail
The Regional Trial Court (RTC) considered the penalty for the offense as reclusion perpetua and thus rejected the bail recommendation, deeming the offense non-bailable. Hu filed a motion for reconsideration, arguing that DOJ Department Circular No. 74, which categorized qualified theft as bailable, should apply.
Court of Appeals Ruling
The Court of Appeals (CA) later sided with Hu, asserting that the crime of qualified theft is bailable under DOJ guidelines. It found the RTC's orders to issue a warrant for Hu's arrest premature and thus nullified them.
Petition for Review on Certiorari
Following the CA’s decision, the People of the Philippines filed a petition for review, arguing that the CA erred by ruling qualified theft bailable solely based on the DOJ circular and that substantial evidence warranted a non-bailable classification.
Argumentation and Legal Basis
The petitioner emphasized that the RTC was acting within its jurisdiction when it issued the orders and that DOJ circulars do not hold binding authority over courts. The petitioner contended that the evidence against Hu indicated a strong case for qualified theft, which is punishable by reclusion perpetua, a condition under which bail is at the court's discretion.
Court's Analysis and Conclusion
The Supreme Court ruled that the argument claiming a right to bail
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Case Background
- The case involves the Extra Excel International Philippines, Inc. (EEIPI), a corporation duly organized under Philippine laws.
- Hu Ruey Chun, also known as Richard Hu, was a stockholder and served as the president and general manager of EEIPI.
- Ralph S. Villanueva held the position of financial manager at EEIPI.
- On September 25, 2001, EEIPI filed a criminal complaint against Hu for qualified theft amounting to PHP 762,076.35.
Allegations of Theft
- Villanueva's affidavit-complaint detailed that:
- Hu had been authorized as the sole signatory for all checks issued by EEIPI during his tenure.
- He ceased being president on December 22, 2000, and was no longer general manager in the latter half of 2000.
- An audit revealed that Hu issued a check payable to himself, drawn against EEIPI's funds, without any legitimate business expense.
- The check in question was dated July 10, 1998, and cleared on July 15, 1998.
Investigation and Initial Rulings
- The Department of Justice (DOJ) conducted a preliminary investigation and initially dismissed the complaint for insufficiency of evidence on December 14, 2001.
- EEIPI appealed this resolution, and on July 10, 2002, the DOJ reversed the dismissal, citing several facts:
- Hu was the sole signatory to corporate checks.
- Hu received the funds from the disputed check.
- There was no Board resolution au